The short answer
For almost every business established outside Germany, holding stock in a German 3PL warehouse means a German VAT registration. There is no turnover threshold for a non-established business. What differs is why you register and what goes on your return. That depends on two facts: whether you are established inside or outside the EU and whether you sell direct or through an online marketplace.
Sellers established outside the EU
Selling direct. A US, UK or Chinese business selling from German stock through its own website makes domestic German supplies. It charges German VAT at 19% or 7% from the first euro and cannot use the German small business exemption. Orders shipped from the German warehouse to consumers in other EU countries are distance sales from the first euro, declared through the One Stop Shop (OSS). The €10,000 distance selling threshold is never available to a non-EU seller.
Selling through a marketplace. Here the position changes. Under German VAT law §3(3a) UStG (Article 14a(2) of the VAT Directive) the marketplace becomes the deemed supplier when a non-EU seller sells goods already in the EU to consumers. The marketplace charges and accounts for German VAT on the consumer sale. The seller’s own supply to the marketplace is exempt but keeps the right to deduct input VAT.
Registration is still required. The seller must recover the import VAT paid when goods enter Germany, report its exempt supplies to the marketplace and account for any stock movements or B2B sales. The return looks very different from a direct seller’s: little or no output VAT and a reclaim of import VAT.
Sellers established in another EU country
The deemed supplier rule does not apply to EU-established sellers. They charge German VAT themselves on sales from German stock, whether they sell direct or through a marketplace. Marketplaces must record each seller’s German VAT ID and can be held liable under §25e UStG for VAT an EU seller fails to pay. In practice: no VAT ID, no listing.
Moving stock into Germany. Transferring your own goods from Poland or Czechia to a German warehouse is an intra-Community transfer. It is an exempt deemed supply in the country of departure and a deemed acquisition in Germany. The German VAT on the acquisition is normally deductible so the net cost is usually nil. The compliance cost is not. Outside the small business scheme the transfer requires a German registration plus an EC Sales List in the departure country. If that country is not your home country you may need a registration there too.
Distance sales. The €10,000 threshold applies only to a seller established in a single EU country, for goods dispatched from that country (it also covers certain electronic services). Germany is not your home country, so sales from German stock to consumers elsewhere in the EU are distance sales from the first euro. The threshold has no bearing on stock moved into Germany.
Small sellers. Since 1 January 2025 EU businesses can use the German small business exemption through the EU small business scheme. German turnover must stay below €25,000 in the previous year and €100,000 in the current year. Total EU turnover must also stay below €100,000, Stock moved into Germany must also stay within the €12,500 acquisition threshold, or the transfer itself can trigger German obligations. A small EU seller using a German 3PL may therefore not need a German registration at all, so eligibility is worth checking before stock moves.
At a glance
| Seller profile | Who charges German VAT on consumer sales | Main reasons to register in Germany |
| Non-EU, selling direct | Seller | Domestic sales; import VAT recovery |
| Non-EU, via marketplace | Marketplace (deemed supplier) | Import VAT recovery; exempt supplies to the marketplace; stock movements |
| EU, direct or via marketplace | Seller | Stock transfers into Germany; domestic sales |
| EU, within the small business scheme | Seller (exempt) | Possibly none; eligibility to be confirmed |
When to register
The legal deadline is set by §138 AO, which requires anyone starting a business to notify the tax office (“Anzeigen über die Erwerbstätigkeit”). Marketplaces ask for a German VAT ID at onboarding and some 3PLs do the same. Plan to hold the number before the first stock movement.
Germany issues two numbers. The Finanzamt allocated to your country of establishment issues a tax number (Steuernummer). The Federal Central Tax Office (BZSt) then issues the VAT identification number (USt-IdNr.).
Processing times vary widely by Finanzamt. Some applications clear within weeks while others take considerably longer. Berlin-Neukölln, which handles sellers established in China, is known for longer lead times and additional checks. Tax offices commonly ask for evidence of German activity such as the 3PL contract, so have it ready when you apply.
Ongoing reporting
Once registered you file periodic German VAT returns plus an annual return. An EC Sales List is filed in Germany only where goods leave Germany for other EU countries, for example B2B sales or onward stock transfers. Intrastat applies only above the 2026 thresholds of €3 million of arrivals or €1 million of dispatches, which most sellers will not reach.
How Tax Desk helps
Tax Desk registers businesses established outside Germany for German VAT and manages what follows: VAT returns, payments instructions for each return and support on audits. Where stock also moves through other EU countries we handle the related registrations, EC Sales Lists and OSS returns. Every client has a dedicated account manager supported by country experts who know how each Finanzamt works and what it will ask for.
Speak to Tax Desk before you sign your 3PL contract.
